Agricultural Quarantine Inspection Program
Management Problems May Increase Vulnerability of U.S. Agriculture to Foreign Pests and Diseases Gao ID: GAO-08-96T October 3, 2007U.S. agriculture generates over $1 trillion in economic activity annually, but concerns exist about its vulnerability to foreign pests and diseases. Under the agricultural quarantine inspection (AQI) program, passengers and cargo are inspected at U.S. ports of entry to intercept prohibited material and pests. The Homeland Security Act of 2002 transferred responsibility for inspections from the U.S. Department of Agriculture's (USDA) Animal and Plant Health Inspection Service (APHIS) to the Department of Homeland Security's (DHS) Customs and Border Protection (CBP). APHIS retained some AQI-related responsibilities, such as policy setting and training. This testimony is based on issued GAO reports and discusses (1) steps DHS and USDA took that were intended to strengthen the AQI program, (2) views of agriculture specialists of their work experiences since the transfer, and (3) management problems. As part of these reports, GAO surveyed a representative sample of agriculture specialists on their work experiences, analyzed inspection and interception data, and interviewed agency officials.
CBP and APHIS have taken steps intended to strengthen the AQI program since transfer of inspection responsibilities from USDA to DHS in March 2003. Specifically, CBP and APHIS have expanded the hours and developed a national standard for agriculture training; given agricultural specialists access to a computer system that is to better target inspections at ports; and established a joint review process for assessing compliance with the AQI program on a port-by-port basis. In addition, CBP has created new agricultural liaison positions at the field office level to advise regional port directors on agricultural issues. We have not assessed the implementation and effectiveness of these actions. However, GAO's survey of CBP agriculture specialists found that many believed the agriculture inspection mission had been compromised by the transfer. Although 86 percent of agriculture specialists reported feeling very well or somewhat prepared for their duties, 59 and 60 percent of specialists answered that they were conducting fewer inspections and interceptions, respectively, of prohibited agricultural items since the transfer. When asked what is going well with respect to their work, agriculture specialists identified working relationships (18 percent), nothing (13 percent), salary and benefits (10 percent), training (10 percent), and general job satisfaction (6 percent). When asked what areas should be changed or improved, they identified working relationships (29 percent), priority given to the agriculture mission (29 percent), problems with the CBP chain of command (28 percent), training (19 percent), and inadequate equipment and supplies (17 percent). Based on private and public sector experiences with mergers, these morale issues are not unexpected because employees often worry about their place in the new organization. CBP must address several management problems to reduce the vulnerability of U.S. agriculture to foreign pests and diseases. Specifically, as of May 2006, CBP had not used available inspection and interception data to evaluate the effectiveness of the AQI program. CBP also had not developed sufficient performance measures to manage and evaluate the AQI program. CBP's measures focused on only two pathways by which foreign pests and diseases may enter the country and pose a threat to U.S. agriculture. However, in early 2007, CBP initiated new performance measures to track interceptions of pests and quarantine materials at ports of entry. We have not assessed the effectiveness of these measures. In addition, CBP has allowed the agricultural canine program to deteriorate, including reductions in the number of canine teams and their proficiency. Lastly, CBP had not developed a risk-based staffing model for determining where to assign agriculture specialists. Without such a model, CBP did not know whether it had an appropriate number of agriculture specialists at each port. Subsequent to our review, CBP developed a model. As of mid-August 2007, CBP had 2,116 agriculture specialists on staff, compared with 3,154 specialists needed, according to the staffing model.
GAO-08-96T, Agricultural Quarantine Inspection Program: Management Problems May Increase Vulnerability of U.S. Agriculture to Foreign Pests and Diseases
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United States Government Accountability Office: GAO:
Testimony Before the Subcommittee on Horticulture and Organic
Agriculture, Committee on Agriculture, House of Representatives:
For Release on Delivery:
Expected at 10:00 a.m. EDT:
Wednesday, October 3, 2007:
Agricultural Quarantine Inspection Program: Management Problems May
Increase Vulnerability of U.S. Agriculture to Foreign Pests and
Diseases:
Statement of Lisa Shames:
Director:
Natural Resources and Environment
GAO-08-96T:
GAO Highlights:
Highlights of GAO-08-96T, a testimony before the Subcommittee on
Horticulture and Organic Agriculture, Committee on Agriculture House of
Representatives.
Why GAO Did This Study:
U.S. agriculture generates over $1 trillion in economic activity
annually, but concerns exist about its vulnerability to foreign pests
and diseases. Under the agricultural quarantine inspection (AQI)
program, passengers and cargo are inspected at U.S. ports of entry to
intercept prohibited material and pests. The Homeland Security Act of
2002 transferred responsibility for inspections from the U.S.
Department of Agriculture‘s (USDA) Animal and Plant Health Inspection
Service (APHIS) to the Department of Homeland Security‘s (DHS) Customs
and Border Protection (CBP). APHIS retained some AQI-related
responsibilities such as policy setting and training.
This testimony is based on issued GAO reports and discusses (1) steps
DHS and USDA took that were intended to strengthen the AQI program, (2)
views of agriculture specialists of their work experience since the
transfer, (3) management problems. As part of these reports, GAO
surveyed a representative sample of agriculture specialists on their
work experiences, analyzed inspection and interception data, and
interviewed agency officials.
What GAO Found:
CBP and APHIS have taken steps intended to strengthen the AQI program
since transfer of inspection responsibilities from USDA to DHS in March
2003. Specifically, CBP and APHIS have expanded the hours and developed
a national standard for agriculture training; given agricultural
specialists access to a computer system that is to better target
inspections at ports; and established a joint review process for
assessing compliance with the AQI program on a port-by-port basis. In
addition, CBP has created new agricultural liaison positions at the
field office level to advise regional port directors on agricultural
issues. We have not assessed the implementation and effectiveness of
these actions.
However, GAO‘s survey of CBP agriculture specialists found that many
believed the agriculture inspection mission had been compromised by the
transfer. Although 86 percent of agriculture specialists reported
feeling very well or somewhat prepared for their duties, 59 and 60
percent of specialists answered that they were conducting fewer
inspections and interceptions, respectively, of prohibited agricultural
items since the transfer. When asked what is going well with respect to
their work, agricultural specialists identified working relationships
(18 percent), nothing (13 percent), salary and benefits (10 percent),
training (10 percent), and general job satisfaction (6 percent). When
asked what areas should be changed or improved, they identified working
relationships (29 percent), priority given to the agriculture mission
(29 percent), problems with the CBP chain of command (28 percent),
training (19 percent), and inadequate equipment and supplies (17
percent). Based on private and public sector experiences with mergers,
these morale issues are not unexpected because employees often worry
about their place in the new organization.
CBP must address several management problems to reduce the
vulnerability of U.S. agriculture to foreign pests and diseases.
Specifically, as of May 2006, CBP had not used available inspection and
interception data to evaluate the effectiveness of the AQI program. CBP
also had not developed sufficient performance measures to manage and
evaluate the AQI program. CBP‘s measures focused on only two pathways
by which foreign pests and diseases may enter the country and pose a
threat to U.S. agriculture. However, in early 2007, CBP initiated new
performance measures to track interceptions of pests and quarantine
materials at ports of entry. We have not assessed the effectiveness of
these measures. In addition, CBP has allowed the agricultural canine
program to deteriorate, including reductions in the number of canine
teams and their proficiency. Lastly, CBP had not developed a risk-based
staffing model for determining where to assign agricultural
specialists. Without such a model, CBP did not know whether it had an
appropriate number of agriculture specialists at each port. Subsequent
to our review, CBP developed a model. As of mid-August 2007, CBP had
2,116 agriculture specialists on staff, compared with 3,154 specialists
needed according to the staffing model.
What GAO Recommends:
GAO previously recommended, in part, that DHS and USDA adopt meaningful
performance measures for assessing the AQI programs‘ effectiveness and
develop a risk based staffing model. The agencies generally concurred
with these recommendations.
To view the full product, including the scope and methodology, click on
[hyperlink, http://GAO-08-96T]. For more information, contact Lisa
Shames, (202) 512-3841 or shamesl@gao.gov.
[End of section]
Mr. Chairman and Members of the Subcommittee: We are pleased to be here
to discuss our work on the agricultural quarantine inspection (AQI)
program. Under the AQI program, international passengers and cargo are
inspected at U.S. ports of entry to seize prohibited material and
intercept foreign agricultural pests. The AQI program is the first line
of defense for agriculture, which is the largest industry and employer
in the United States, generating more than $1 trillion in economic
activity annually. The entry of foreign pests and diseases can harm
this important sector of our economy, the environment, plant and animal
health, the food supply, and public health. The U.S. Department of
Agriculture (USDA) estimates that foreign pests and diseases cost the
American economy tens of billions of dollars annually in lower crop
values, eradication programs, and emergency payments to farmers. The
terrorist attacks of September 11, 2001 heightened concerns about
agriculture‘s vulnerability to terrorism, including the deliberate
introduction of livestock, poultry, and crop diseases, such as foot-and-
mouth disease or avian influenza.
The Homeland Security Act of 2002 transferred responsibility for
agricultural quarantine inspections from USDA to the Department of
Homeland Security‘s (DHS) Customs and Border Protection (CBP) effective
in March 2003, but left certain other agricultural quarantine
responsibilities with USDA‘s Animal and Plant Health Inspection Service
(APHIS). APHIS‘s responsibilities are to set agriculture inspection
policy, provide related training, and collect AQI user fees. Beginning
in March 2003, more than 1,800 agriculture specialists who had formerly
reported to USDA became CBP employees, as CBP incorporated the
protection of U.S. agriculture into its primary anti-terrorism mission.
In addition to protecting U.S. agriculture and other functions, CBP‘s
mission is to detect and prevent terrorists and their weapons from
entering the United States, interdict illegal drugs and other
contraband, and apprehend individuals who are attempting to enter the
United States illegally. CBP faces a daunting task in protecting U.S.
agriculture from accidental or deliberate introduction of diseases or
pests, while attending to these missions.
After examining concerns that the transfer of agricultural inspections
to CBP could shift the focus away from agriculture to CBP‘s other
mission priorities, we reported in May 2006 on the coordination between
USDA and DHS and made several recommendations to help ensure that U.S.
agriculture is protected from accidentally or intentionally introduced
pests and diseases. [Footnote 1] USDA and DHS generally agreed with the
report‘s recommendations. In preparing this report, we surveyed a
representative sample of CBP‘s agriculture specialists on their work
experiences before and after the transfer and included the responses to
the survey‘s 31 multiple-choice questions in the report.[ Footnote 2]
The survey also asked two open-ended questions: (1) What is going well
with respect to your work as an agriculture specialist? and (2) What
would you like to see changed or improved with respect to your work as
an agriculture specialist? In November 2006, we separately reported on
the common themes in the narrative responses. [Footnote 3] My testimony
today is based on these two reviews. We conducted the reviews from
April 2005 through October 2006 in accordance with generally accepted
government auditing standards.
This morning I will focus on three key findings:
* CBP and APHIS have taken steps intended to strengthen the AQI program
since the transfer of inspection responsibilities from USDA to DHS
following passage of the Homeland Security Act of 2002. CBP and APHIS
have expanded the hours of agricultural training for CBP officers and
developed a national standard for this training; given agriculture
specialists access to CBP‘s Automated Targeting System to focus
inspections on higher-risk passengers and cargo; and established a
joint review process for assessing compliance with the AQI program on a
port-by-port basis. Lastly, CBP has created new agricultural liaison
positions at the field office level to advise regional port directors
on agricultural issues. We have not assessed the implementation and
effectiveness of these actions.
* Our survey of CBP agriculture specialists found that many believe the
agriculture inspection mission has been compromised by the transfer.
Although 86 percent of agriculture specialists reported feeling very
well prepared or somewhat prepared for their duties, 59 and 60 percent
of specialists answered that they were conducting fewer inspections and
interceptions, respectively, of prohibited agricultural items since the
transfer. When asked what is going well with respect to their work,
agriculture specialists identified working relationships (18 percent),
nothing (13 percent), salary and benefits (10 percent), training (10
percent), and general job satisfaction (6 percent). When asked what
areas should be changed or improved, they identified working
relationships (29 percent), priority given to the agriculture mission
(29 percent), problems with the CBP chain of command (28 percent),
training (19 percent), and inadequate equipment and supplies (17
percent). Agriculture specialists typically provided more examples or
went into greater detail in answering these questions and submitted 185
pages of comments about what needs improvement”roughly 4 times more
than their responses about what was going well. Based on private and
public sector experiences with mergers, these morale issues are not
unexpected because employees often worry about their place in the new
organization.
* CBP must address several management challenges to reduce the
vulnerability of U.S. agriculture to foreign pests and diseases.
Specifically, as of our May 2006 report, CBP had not used available
inspection and interception data to evaluate the effectiveness of the
AQI program, although the agency told us it has subsequently taken some
steps”such as publishing monthly reports on inspections, arrivals, and
seizures of various prohibited items, including agricultural quarantine
material and pest interceptions”that we have not evaluated. Moreover,
at the time of our May 2006 review, CBP had not developed sufficient
performance measures to manage and evaluate the AQI program. CBP‘s
measures focused only on two pathways”the percentage of (1)
international air passengers and (2) border vehicle passengers that
comply with AQI regulations”by which foreign pests and diseases may
enter the country, but did not consider other important pathways such
as commercial aircraft, vessels, and truck cargo that may pose a risk
to U.S. agriculture. In early 2007, a joint team from CBP and APHIS
agreed to implement additional performance measures for AQI activities
in all major pathways at ports of entry. Some of these measures were
implemented in fiscal year 2007; others are planned for fiscal years
2008 and 2009. However, we have not evaluated the adequacy of these new
measures for assessing the AQI program‘s effectiveness at intercepting
foreign pests and diseases. In addition, CBP has allowed the
agriculture canine program to deteriorate, with fewer canine teams and
declining proficiency scores. In the past, these dogs have been a key
tool for targeting passengers and cargo for detailed inspections.
Lastly, CBP does not have the agriculture specialists needed to perform
its AQI responsibilities based on its staffing model. Specifically, as
of mid-August 2007, CBP said it had 2,116 agriculture specialists on
staff, compared to 3,154 specialists needed, according to the model.
CBP and APHIS Have Taken Steps Intended to Strengthen the AQI Program:
CBP and APHIS have taken four major steps intended to strengthen the
AQI program since the transfer of responsibilities following passage of
the Homeland Security Act of 2002. To date, we have not done work to
assess the implementation and effectiveness of these actions.
First, CBP and APHIS expanded the hours of training on agricultural
issues for CBP officers, whose primary duty is customs and immigration
inspection, and for CBP agriculture specialists, whose primary duty is
agricultural inspection. Specifically, newly hired CBP officers receive
16 hours of training on agricultural issues, whereas before the
transfer to CBP, customs inspectors received 4 hours of agricultural
training, and immigration inspectors received 2 hours. CBP and APHIS
also expanded agriculture training for CBP officers at their respective
ports of entry to help them make better-informed decisions on
agricultural items at high-volume border traffic areas. Additionally,
CBP and APHIS have standardized the in-port training program and have
developed a national standard for agriculture specialists with a
checklist of activities for agriculture specialists to master. These
activities are structured into an 8-week module on passenger inspection
procedures and a 10-week module on cargo inspection procedures. Based
on our survey of agriculture specialists, we estimate that 75 percent
of specialists hired by CBP believe that they received sufficient
training (on the job and at the Professional Development Center) to
enable them to perform their agriculture inspection duties. [Footnote
4]
Second, CBP and APHIS have taken steps designed to better target
shipments and passengers that potentially present a high risk to U.S.
agriculture. Specifically, some CBP agriculture specialists received
training and were given access to CBP‘s Automated Targeting System, a
computer system that, among other things, is designed to focus limited
inspection resources on higher-risk passengers and cargo and facilitate
expedited clearance or entry for low-risk passengers and cargo. This
system gives agriculture specialists detailed information from cargo
manifests and other documents that shipping companies are required to
submit before the ship arrives in a port to help them select high-risk
cargo for inspection. CBP and APHIS headquarters personnel also use
this information to identify companies that had previously violated
U.S. quarantine laws. For example, according to a senior APHIS
official, the two agencies used this system to help identify companies
that have used seafood containers to smuggle uncooked poultry products
from Asia, which are currently banned because of concerns over avian
influenza.
Third, CBP and APHIS established a formal assessment process intended
to ensure that ports of entry carry out agricultural inspections in
accordance with the agricultural quarantine inspection program‘s
regulations, policies, and procedures. The process, called Joint Agency
Quality Assurance Reviews, covers topics such as (1) CBP coordination
with other federal agencies; (2) agriculture specialist training; (3)
specialist access to regulatory manuals; and (4) specialist adherence
to processes for handling violations at the port, inspecting passenger
baggage and vehicles, and intercepting, seizing, and disposing of
confiscated materials. The reviews address best practices and
deficiencies at each port and make recommendations for corrective
actions to be implemented within 6 weeks. For example, regarding best
practices, a review of two ports found that the placement of CBP,
APHIS, and Food and Drug Administration staff in the same facility
enhanced their coordination. This review also lauded their targeting of
non-agricultural products that are packed with materials, such as wood,
that may harbor pests or diseases that could pose a risk to U.S.
agriculture. Regarding deficiencies, this review found that the number
of CBP agriculture specialists in each port was insufficient, and that
the specialists at one of the ports were conducting superficial
inspections of commodities that should have been inspected more
intensely. According to CBP, the agency took actions to correct these
deficiencies, although we have not evaluated those actions. In
September 2007, CBP said that the joint review team had conducted 13
reviews in fiscal years 2004 through 2006, and 7 reviews were completed
or underway for fiscal year 2007. Seven additional reviews are planned
for fiscal year 2008.
Lastly, in May 2005, CBP required each director in its 20 district
field offices to appoint an agriculture liaison, with background and
experience as an agriculture specialist, to provide CBP field office
directors with agriculture-related input for operational decisions and
agriculture specialists with senior-level leadership. The agriculture
liaisons are to, among other things, advise the director of the field
office on agricultural functions; provide oversight for data
management, statistical analysis, and risk management; and coordinate
agriculture inspection alerts. CBP officials told us that all district
field offices had established the liaison position as of January 2006.
Since the creation of the position, agriculture liaisons have
facilitated the dissemination of urgent alerts from APHIS to CBP. They
also provide information back to APHIS. For example, following a large
increase in the discovery of plant pests at a port in November 2005,
the designated agriculture liaison sent notice to APHIS, which then
issued alerts to other ports. APHIS and CBP subsequently identified
this agriculture liaison as a contact for providing technical advice
for inspecting and identifying this type of plant pest.
Many Agriculture Specialists Believe that the Agricultural Mission Has
Been Compromised:
In fiscal year 2006, we surveyed a representative sample of CBP
agriculture specialists regarding their experiences and opinions since
the transfer of the AQI program from APHIS to CBP. [Footnote 5] In
general, the views expressed by these specialists indicate that they
believe that the agricultural inspection mission has been compromised.
We note that morale issues are not unexpected in a merger such as the
integration of the AQI mission and staff into CBP‘s primary anti-
terrorism mission. GAO has previously reported on lessons learned from
major private and public sector experiences with mergers that DHS could
use when combining its various components into a unified department.
[Footnote 6] Among other things, productivity and effectiveness often
decline in the period following a merger, in part because employees
often worry about their place in the new organization.
Nonetheless, based on the survey results, while 86 percent of
specialists reported feeling very well or somewhat prepared for their
duties as an agriculture specialist, many believed that the agriculture
mission had been compromised by the transfer. Specifically,
* 59 percent of experienced specialists indicated that they are doing
either somewhat or many fewer inspections since the transfer, and 60
percent indicated that they are doing somewhat or many fewer
interceptions;
* 63 percent of agriculture specialists believed their port did not
have enough specialists to carry out agriculture-related duties;
* Agriculture specialists reported that they spent 62 percent of their
time on agriculture inspections, whereas 35 percent of their time was
spent on non-agricultural functions such as customs and immigration
inspections.
In addition, there appear to be morale issues based on the responses to
two open-ended questions: (1) What is going well with respect to your
work as an agriculture specialist? and (2) What would you like to see
changed or improved with respect to your work as an agriculture
specialist? Notably, the question about what needs improving generated
a total of 185 pages of comments”roughly 4 times more than that
generated by the responses to our question on what was going well.
Further, ’Nothing is going well“ was the second-most frequent response
to the question on what is going well.
We identified common themes in the agriculture specialists‘ responses
to our first question about what is going well with respect to their
work as an agriculture specialist. The five most common themes were:
* Working relationships. An estimated 18 percent of agriculture
specialists cited the working relationship among agriculture
specialists and CBP officers and management as positive. These
specialists cited increasing respect and interest by non-specialists in
the agriculture mission, and the attentiveness of CBP management to
agriculture specialists‘ concerns;
* Nothing. An estimated 13 percent of agriculture specialists reported
that nothing is going well with their work. For example, some
respondents noted that the agriculture inspection mission has been
compromised under CBP and that agriculture specialists are no longer
important or respected by management;
* Salary and Benefits. An estimated 10 percent of agriculture
specialists expressed positive comments about their salary and
benefits, with some citing increased pay under CBP, a flexible work
schedule, increased overtime pay, and retirement benefits as reasons
for their views;
* Training. An estimated 8 percent of agriculture specialists
identified elements of classroom and on-the-job training as going well.
Some observed that new hires are well trained and that agriculture-
related classroom training at the Professional Development Center in
Frederick, Maryland, is adequate for their duties;
* General job satisfaction. An estimated 6 percent of agriculture
specialists were generally satisfied with their jobs, reporting, among
other things, that they were satisfied in their working relationships
with CBP management and coworkers and that they believed in the
importance of their work in protecting U.S. agriculture from foreign
pests and diseases.
In contrast, agriculture specialists wrote nearly 4 times as much in
response to our question about what they would like to see changed or
improved with respect to their work as agriculture specialists. In
addition, larger proportions of specialists identified each of the top
five themes.
* Declining mission. An estimated 29 percent of agriculture specialists
were concerned that the agriculture mission is declining because CBP
has not given it adequate priority. Some respondents cited the increase
in the number of cargo items and flights that are not inspected because
of staff shortages, scheduling decisions by CBP port management, and
the release of prohibited or restricted products by CBP officers;
* Working relationships. An estimated 29 percent of the specialists
expressed concern about their working relationships with CBP officers
and management. Some wrote that CBP officers at their ports view the
agriculture mission as less important than CBP‘s other priorities, such
as counternarcotics and anti-terrorism activities. Others noted that
CBP management is not interested in, and does not support, agriculture
inspections;
* CBP chain of command. An estimated 28 percent of agriculture
specialists identified problems with the CBP chain of command that
impede timely actions involving high-risk interceptions, such as a lack
of managers with an agriculture background and the agency‘s rigid chain-
of-command structure. For example, agriculture specialists wrote that
requests for information from USDA pest identification experts must be
passed up the CBP chain of command before they can be conveyed to
USDA;
* Training. An estimated 19 percent of agriculture specialists believed
that training in the classroom and on the job is inadequate. For
example, some respondents expressed concern about a lack of courses on
DHS‘s targeting and database systems, which some agriculture
specialists use to target high-risk shipments and passengers. Also,
some agriculture specialists wrote that on-the-job training at their
ports is poor, and that CBP officers do not have adequate agriculture
training to recognize when to refer items to agriculture specialists
for inspection;
* Lack of equipment. An estimated 17 percent of agriculture specialists
were concerned about a lack of equipment and supplies. Some respondents
wrote that the process for purchasing items under CBP results in delays
in acquiring supplies and that there is a shortage of agriculture-
specific supplies, such as vials, gloves, and laboratory equipment.
These themes are consistent with responses to relevant multiple-choice
questions in the survey. For example, in response to one of these
questions, 61 percent of agriculture specialists believed their work
was not respected by CBP officers, and 64 percent believed their work
was not respected by CBP management.
Management Problems May Leave U.S. Agriculture Vulnerable to Foreign
Pests and Diseases:
Although CBP and APHIS have taken a number of actions intended to
strengthen the AQI program since its transfer to CBP, several
management problems remain that may leave U.S. agriculture vulnerable
to foreign pests and diseases. Most importantly, CBP has not used
available data to evaluate the effectiveness of the program. These data
are especially important in light of many agriculture specialists‘
views that the agricultural mission has been compromised and can help
CBP determine necessary actions to close any performance gaps.
Moreover, at the time of our May 2006 review, CBP had not developed
sufficient performance measures to manage and evaluate the AQI program,
and the agency had allowed the agricultural canine program to
deteriorate. Furthermore, based on its staffing model, CBP does not
have the agriculture specialists needed to perform its AQI
responsibilities.
CBP has not used available data to monitor changes in the frequency
with which prohibited agricultural materials and reportable pests are
intercepted during inspection activities. CBP agriculture specialists
record monthly data in the Work Accomplishment Data System for each
port of entry, including (1) arrivals of passengers and cargo to the
United States via airplane, ship, or vehicle; (2) agricultural
inspections of arriving passengers and cargo; and (3) inspection
outcomes, i.e., seizures or detections of prohibited (quarantined)
agricultural materials and reportable pests. As of our May 2006 report,
CBP had not used these data to evaluate the effectiveness of the AQI
program.
For example, our analysis of the data for the 42 months before and 31
months after the transfer of responsibilities from APHIS to CBP shows
that average inspection and interception rates have changed
significantly in some geographical regions of the United States, with
rates increasing in some regions and decreasing in others. (Appendixes
I and II provide more information on average inspection and
interception rates before and after the transfer from APHIS to CBP.)
Specifically, average inspection rates declined significantly in the
Baltimore, Boston, Miami, and San Francisco district field offices, and
in preclearance locations in Canada, the Caribbean, and Ireland.
Inspection rates increased significantly in seven other
districts”Buffalo, El Paso, Laredo, San Diego, Seattle, Tampa, and
Tucson. In addition, the average rate of interceptions decreased
significantly at ports in six district field offices”El Paso, New
Orleans, New York, San Juan, Tampa, and Tucson”while average
interception rates have increased significantly at ports in the
Baltimore, Boston, Detroit, Portland, and Seattle districts.
Of particular note are three districts that have experienced a
significant increase in their rate of inspections and a significant
decrease in their interception rates since the transfer. Specifically,
since the transfer, the Tampa, El Paso, and Tucson districts appear to
be more efficient at inspecting (e.g., inspecting a greater proportion
of arriving passengers or cargo) but less effective at interceptions
(e.g., intercepting fewer prohibited agricultural items per
inspection). Also of concern are three districts”San Juan, New Orleans,
and New York”that are inspecting at about the same rate, but
intercepting less, since the transfer.
When we showed the results of our analysis to senior CBP officials,
they were unable to explain these changes or determine whether the
current rates were appropriate relative to the risks, staffing levels,
and staff expertise associated with individual districts or ports of
entry. These officials also noted that CBP has had problems
interpreting APHIS data reports because CBP lacked staff with expertise
in agriculture and APHIS‘s data systems in some district offices. As of
our May 2006 report, CBP had not yet completed or implemented its plan
to add agriculture-related data to its system for monitoring customs
inspections. However, in September 2007, CBP said it had taken steps to
use these data to evaluate the program‘s effectiveness. For example,
CBP publishes a monthly report that includes analysis of efficiency
inspections, arrivals, exams, and seizures of prohibited items,
including agricultural quarantine material and pest interceptions, for
each pathway. CBP also conducts a mid-year analysis of APHIS and CBP
data to assess agricultural inspection efficiency at ports of entry.
While these appear to be positive steps, we have not assessed their
adequacy to measure the AQI program‘s effectiveness.
A second management problem for the AQI program is an incomplete set of
performance measures to balance multiple responsibilities and
demonstrate results. As of our May 2006 report, CBP had not developed
and implemented its own performance measures for the program. Instead,
according to CBP officials, CBP carried over two measures that APHIS
had used to assess the AQI program before the transfer: the percentages
of international air passengers and border vehicle passengers that
comply with program regulations. However, these measures addressed only
two pathways for agricultural pests, neglecting other pathways such as
commercial aircraft, vessels, and truck cargo. Further, these
performance measures did not provide information about changes in
inspection and interception rates, which could help assess the
efficiency and effectiveness of agriculture inspections in different
regions of the country or at individual ports of entry. They also did
not address the AQI program‘s expanded mission”to prevent agro-
terrorism while facilitating the flow of legitimate trade and travel.
In early 2007, a joint team from CBP and APHIS agreed to implement
additional performance measures for AQI activities in all major
pathways at ports of entry. Specifically, CBP said that in fiscal year
2007 it implemented measures for the percentages of land border, air,
and maritime regulated cargo and shipments in compliance with AQI
regulations. Furthermore, the agency plans to add additional
performance measures such as percentage of passengers, vehicles, or
mail in compliance in fiscal years 2008 and 2009. However, we have not
evaluated the adequacy of these new performance measures for assessing
the AQI program‘s effectiveness at intercepting foreign pests and
diseases.
Third, the number and proficiency of canine teams decreased
substantially between the time of the transfer, March 2003, and the
time of our review, May 2006. In the past, these dogs have been a key
tool for targeting passengers and cargo for detailed inspections.
Specifically, APHIS had approximately 140 canine teams nationwide at
the time of the transfer, but CBP had only 80 such teams at the time of
our review. With regard to proficiency, 60 percent of the 43
agriculture canine teams tested by APHIS in 2005 failed proficiency
tests. These tests require the dog to respond correctly in a
controlled, simulated work environment and ensure that dogs are working
effectively to catch potential prohibited agricultural material. In
general, canine specialists we interviewed expressed concern that the
proficiency of their dogs was deteriorating due to a lack of working
time. That is, the dogs were sidelined while the specialists were
assigned to other duties. In addition, based on our survey results, 46
percent of canine specialists said they were directed to perform duties
outside their primary canine duties daily or several times a week.
Furthermore, 65 percent of canine specialists indicated that they
sometimes or never had funding for training supplies. Another major
change to the canine program, following the transfer, was CBP‘s
elimination of all canine management positions.
Finally, based on its staffing model, CBP lacks adequate numbers of
agriculture specialists to accomplish the agricultural mission. The
Homeland Security Act authorized the transfer of up to 3,200 AQI
personnel from USDA to DHS. In March 2003, APHIS transferred a total of
1,871 agriculture specialist positions, including 317 vacancies, to CBP
and distributed those positions across CBP‘s 20 district field offices,
encompassing 139 ports of entry. Because of the vacancies, CBP lacked
adequate numbers of agriculture specialists from the beginning and had
little assurance that appropriate numbers of specialists were staffed
at each port of entry. Although CBP has made some progress in hiring
agriculture specialists since the transfer, we previously reported that
CBP lacked a staffing model to ensure that more than 630 newly hired
agriculture specialists were assigned to the ports with the greatest
need, and to ensure that each port had at least some experienced
specialists. Accordingly, in May 2006 we recommended that APHIS and CBP
work together to develop a national staffing model to ensure that
agriculture staffing levels at each port are sufficient. Subsequently,
CBP developed a staffing model for its ports of entry and provided GAO
with its results. Specifically, as of mid-August 2007, CBP said it had
2,116 agriculture specialists on staff, compared to 3,154 such
specialists needed according to the model.
Conclusions:
The global marketplace of agricultural trade and international travel
has increased the number of pathways for the movement and introduction
into the United States of foreign and invasive agricultural pests and
diseases such as foot-and-mouth disease and avian influenza. Given the
importance of agriculture to the U.S. economy, ensuring the
effectiveness of federal programs to prevent accidental or deliberate
introduction of potentially destructive organisms is critical.
Accordingly, effective management of the AQI program is necessary to
ensure that agriculture issues receive appropriate attention. Although
we have reported that CBP and APHIS have taken steps to strengthen
agricultural quarantine inspections, many agriculture specialists
believe that the agricultural mission has been compromised. While
morale issues, such as the ones we identified, are to be expected in
the merger establishing DHS, CBP had not used key data to evaluate the
program‘s effectiveness and could not explain significant increases and
decreases in inspections and interceptions. In addition, CBP had not
developed performance measures to demonstrate that it is balancing its
multiple mission responsibilities, and it does not have sufficient
agriculture specialists based on its staffing model. Until the
integration of agriculture issues into CBP‘s overall anti-terrorism
mission is more fully achieved, U.S. agriculture may be left vulnerable
to the threat of foreign pests and diseases.
Mr. Chairman, this concludes my prepared statement. I would be happy to
respond to any questions that you or Members of the Subcommittee may
have at this time.
Contact and Staff Acknowledgments:
Contact points for our Offices of Congressional Relations and Public
Affairs may be found on the last page of this statement. For further
information about this testimony, please contact Lisa Shames at (202)
512-3841 or shamesl@gao.gov. Key contributors to this testimony were
James Jones, Jr., Assistant Director, and Terrance Horner, Jr. Josey
Ballenger, Kevin Bray, Chad M. Gorman, Lynn Musser, Omari Norman,
Alison O‘Neill, and Steve C. Rossman also made important
contributions.
[End of section]
Appendix I: Average Inspection Rates Before and After the Transfer From
APHIS to CBP:
Table 1: Average Inspection Rates before and after the Transfer from
APHIS to CBP:
District field office: Atlanta;
Average inspection rate before (October 1999-February 2003): 9.7;
Average inspection rate after (March 2003-September 2005): 8.8;
Difference[a]: -0.9;
Statistical significance[b]: No.
District field office: Baltimore;
Average inspection rate before (October 1999-February 2003): 18.2;
Average inspection rate after (March 2003-September 2005): 10.0;
Difference[a]: -8.2;
Statistical significance[b]: Yes.
District field office: Boston;
Average inspection rate before (October 1999-February 2003): 30.9;
Average inspection rate after (March 2003-September 2005): 13.0;
Difference[a]: -17.9;
Statistical significance[b]: Yes.
District field office: Buffalo;
Average inspection rate before (October 1999-February 2003): 0.1;
Average inspection rate after (March 2003-September 2005): 0.5;
Difference[a]: 0.3;
Statistical significance[b]: Yes.
District field office: Chicago;
Average inspection rate before (October 1999-February 2003): 18.0;
Average inspection rate after (March 2003-September 2005): 18.5;
Difference[a]: 0.5;
Statistical significance[b]: No.
District field office: Detroit;
Average inspection rate before (October 1999-February 2003): 3.1;
Average inspection rate after (March 2003-September 2005): 2.9;
Difference[a]: -0.2;
Statistical significance[b]: No.
District field office: El Paso;
Average inspection rate before (October 1999-February 2003): 2.9;
Average inspection rate after (March 2003-September 2005): 4.4;
Difference[a]: 1.5;
Statistical significance[b]: Yes.
District field office: Houston;
Average inspection rate before (October 1999-February 2003): 13.2;
Average inspection rate after (March 2003-September 2005): 12.1;
Difference[a]: -1.1;
Statistical significance[b]: No.
District field office: Laredo;
Average inspection rate before (October 1999-February 2003): 7.7;
Average inspection rate after (March 2003-September 2005): 8.8;
Difference[a]: 1.1;
Statistical significance[b]: Yes.
District field office: Los Angeles; Average inspection rate before
(October 1999-February 2003): 12.5; Average inspection rate after
(March 2003-September 2005): 10.4; Difference[a]: -2.1;
Statistical significance[b]: No.
District field office: Miami;
Average inspection rate before (October 1999-February 2003): 35.8;
Average inspection rate after (March 2003-September 2005): 23.1;
Difference[a]: -12.7;
Statistical significance[b]: Yes.
District field office: New Orleans; Average inspection rate before
(October 1999-February 2003): 37.6; Average inspection rate after
(March 2003-September 2005): 41.8; Difference[a]: 4.3;
Statistical significance[b]: No.
District field office: New York;
Average inspection rate before (October 1999-February 2003): 12.0;
Average inspection rate after (March 2003-September 2005): 11.8;
Difference[a]: -0.2;
Statistical significance[b]: No.
District field office: Preclearance[c]; Average inspection rate before
(October 1999-February 2003): 7.8; Average inspection rate after (March
2003-September 2005): 3.4; Difference[a]: -4.4;
Statistical significance[b]: Yes.
District field office: Portland;
Average inspection rate before (October 1999-February 2003): 13.0;
Average inspection rate after (March 2003-September 2005): 12.6;
Difference[a]: -0.4;
Statistical significance[b]: No.
District field office: San Diego;
Average inspection rate before (October 1999-February 2003): 12.6;
Average inspection rate after (March 2003-September 2005): 16.3;
Difference[a]: 3.6;
Statistical significance[b]: Yes.
District field office: San Francisco; Average inspection rate before
(October 1999-February 2003): 40.4; Average inspection rate after
(March 2003-September 2005): 19.0; Difference[a]: -21.4;
Statistical significance[b]: Yes.
District field office: San Juan;
Average inspection rate before (October 1999-February 2003): 62.4;
Average inspection rate after (March 2003-September 2005): 57.6;
Difference[a]: -4.8;
Statistical significance[b]: No.
District field office: Seattle;
Average inspection rate before (October 1999-February 2003): 2.3;
Average inspection rate after (March 2003-September 2005): 3.1;
Difference[a]: 0.8;
Statistical significance[b]: Yes.
District field office: Tampa;
Average inspection rate before (October 1999-February 2003): 19.6;
Average inspection rate after (March 2003-September 2005): 30.7;
Difference[a]: 11.1;
Statistical significance[b]: Yes.
District field office: Tucson;
Average inspection rate before (October 1999-February 2003): 2.6;
Average inspection rate after (March 2003-September 2005): 4.0;
Difference[a]: 1.4;
Statistical significance[b]: Yes.
Source: GAO calculations of APHIS‘s Work Accomplishment Data System,
fiscal years 2000 through 2005.
[a] Because of rounding, values in the difference column may not equal
the difference between rounded inspection rates.
[b] Statistical significance for each field office was calculated at
the 99.75 percent confidence level so that the confidence level of all
21 statistical significance outcomes, collectively, is about 95
percent.
[c] Preclearance inspections were conducted at 14 locations in Canada,
the Caribbean, and Ireland. Individuals arriving in the U.S. from those
locations did not undergo another inspection upon arrival in the United
States. According to CBP, preclearance inspections were done only as a
pilot and not as an ongoing program within the agency.
End of table]
[End of section]
Appendix II: Average Interception Rates Before and After the Transfer
From APHIS to CBP:
Table 2: Average Interception Rates before and after the Transfer from
APHIS to CBP:
District field office: Atlanta;
Average interception rate before (October 1999-February 2003): 10.7;
Average interception rate after (March 2003-September 2005): 11.5;
Difference[a]: 0.8;
Statistical significance[b]: No.
District field office: Baltimore;
Average interception rate before (October 1999-February 2003): 7.6;
Average interception rate after (March 2003-September 2005): 10.4;
Difference[a]: 2.8;
Statistical significance[b]: Yes.
District field office: Boston;
Average interception rate before (October 1999-February 2003): 3.9;
Average interception rate after (March 2003-September 2005): 12.4;
Difference[a]: 8.5;
Statistical significance[b]: Yes.
District field office: Buffalo;
Average interception rate before (October 1999-February 2003): 15.4;
Average interception rate after (March 2003-September 2005): 30.2;
Difference[a]: 14.8;
Statistical significance[b]: No.
District field office: Chicago;
Average interception rate before (October 1999-February 2003): 6.8;
Average interception rate after (March 2003-September 2005): 5.6;
Difference[a]: -1.3;
Statistical significance[b]: No.
District field office: Detroit;
Average interception rate before (October 1999-February 2003): 7.7;
Average interception rate after (March 2003-September 2005): 20.7;
Difference[a]: 13.0;
Statistical significance[b]: Yes.
District field office: El Paso;
Average interception rate before (October 1999-February 2003): 9.4;
Average interception rate after (March 2003-September 2005): 5.7;
Difference[a]: -3.7;
Statistical significance[b]: Yes.
District field office: Houston;
Average interception rate before (October 1999-February 2003): 7.9;
Average interception rate after (March 2003-September 2005): 8.4;
Difference[a]: 0.4;
Statistical significance[b]: No.
District field office: Laredo;
Average interception rate before (October 1999-February 2003): 4.4;
Average interception rate after (March 2003-September 2005): 3.9;
Difference[a]: -0.5;
Statistical significance[b]: No.
District field office: Los Angeles; Average interception rate before
(October 1999-February 2003): 7.4; Average interception rate after
(March 2003-September 2005): 8.7; Difference[a]: 1.3;
Statistical significance[b]: No.
District field office: Miami;
Average interception rate before (October 1999-February 2003): 5.3;
Average interception rate after (March 2003-September 2005): 5.8;
Difference[a]: 0.4;
Statistical significance[b]: No.
District field office: New Orleans; Average interception rate before
(October 1999-February 2003): 5.9; Average interception rate after
(March 2003-September 2005): 3.5; Difference[a]: -2.4;
Statistical significance[b]: Yes.
District field office: New York;
Average interception rate before (October 1999-February 2003): 18.1;
Average interception rate after (March 2003-September 2005): 10.2;
Difference[a]: -7.9;
Statistical significance[b]: Yes.
District field office: Preclearance[c]; Average interception rate
before (October 1999-February 2003): 10.1; Average interception rate
after (March 2003-September 2005): 24.4; Difference[a]: 14.2;
Statistical significance[b]: Yes.
District field office: Portland;
Average interception rate before (October 1999-February 2003): 9.6;
Average interception rate after (March 2003-September 2005): 14.9;
Difference[a]: 5.3;
Statistical significance[b]: Yes.
District field office: San Diego;
Average interception rate before (October 1999-February 2003): 1.3;
Average interception rate after (March 2003-September 2005): 1.4;
Difference[a]: 0.2;
Statistical significance[b]: No.
District field office: San Francisco; Average interception rate before
(October 1999-February 2003): 10.5; Average interception rate after
(March 2003-September 2005): 10.6; Difference[a]: 0.1;
Statistical significance[b]: No.
District field office: San Juan;
Average interception rate before (October 1999-February 2003): 6.1;
Average interception rate after (March 2003-September 2005): 3.5;
Difference[a]: -2.5;
Statistical significance[b]: Yes.
District field office: Seattle;
Average interception rate before (October 1999-February 2003): 30.1;
Average interception rate after (March 2003-September 2005): 46.5;
Difference[a]: 16.4;
Statistical significance[b]: Yes.
District field office: Tampa;
Average interception rate before (October 1999-February 2003): 8.3;
Average interception rate after (March 2003-September 2005): 3.0;
Difference[a]: -5.2;
Statistical significance[b]: Yes.
District field office: Tucson;
Average interception rate before (October 1999-February 2003): 9.0;
Average interception rate after (March 2003-September 2005): 7.0;
Difference[a]: -2.0;
Statistical significance[b]: Yes.
Source: GAO calculations of APHIS‘s Work Accomplishment Data System,
fiscal years 2000 through 2005.
[a] Because of rounding, values in the difference column may not equal
the difference between rounded inspection rates.
[b] Statistical significance for each field office was calculated at
the 99.75 percent confidence level so that the confidence level of all
21 statistical significance outcomes, collectively, is about 95
percent.
[c] Preclearance inspections were conducted at 14 locations in Canada,
the Caribbean, and Ireland. Individuals arriving in the U.S. from those
locations did not undergo another inspection upon arrival in the United
States. According to CBP, preclearance inspections were done only as a
pilot and not as an ongoing program within the agency.
End of table]
[End of section]
Related GAO Products:
Department of Homeland Security: Progress Report on Implementation of
Mission and Management Functions. GAO-07-1240T. Washington, D.C.:
September 18, 2007.
Department of Homeland Security: Progress Report on Implementation of
Mission and Management Functions. GAO-07-454. Washington, D.C.: August
17, 2007.
Customs Revenue: Customs and Border Protection Needs to Improve
Workforce Planning and Accountability. GAO-07-529. Washington, D.C.:
April 12, 2007.
Homeland Security: Agriculture Specialists‘ Views of Their Work
Experiences after Transfer to DHS. GAO-07-209R. Washington, D.C.:
November 14, 2006.
Invasive Forest Pests: Recent Infestations and Continued
Vulnerabilities at Ports of Entry Place U.S. Forests at Risk. GAO-06-
871T. Washington, D.C.: June 21, 2006.
Homeland Security: Management and Coordination Problems Increase the
Vulnerability of U.S. Agriculture to Foreign Pests and Disease. GAO-06-
644. Washington, D.C.: May 19, 2006.
Homeland Security: Much Is Being Done to Protect Agriculture from a
Terrorist Attack, but Important Challenges Remain. GAO-05-214.
Washington, D.C.: March 8, 2005.
Results-Oriented Cultures: Implementation Steps to Assist Mergers and
Organizational Transformations. GAO-03-669. Washington, D.C.: July 2,
2003.
Mergers and Transformation: Lessons Learned for a Department of
Homeland Security and Other Federal Agencies. GAO-03-293SP. Washington,
D.C.: November 14, 2002.
Homeland Security: Critical Design and Implementation Issues. GAO-02-
957T. Washington, D.C.: July 17, 2002.
[End of section]
Footnotes:
[1] GAO, Homeland Security: Management and Coordination Problems
Increase the Vulnerability of U.S. Agriculture to Foreign Pests and
Disease, GAO-06-644 (Washington, D.C.: May 19, 2006).
[2] Specifically, we drew a random probability sample of 831
agriculture specialists from the approximately 1,800 specialists
(current as of Oct. 14, 2005) in CBP. In general, strata were defined
by the number of specialists at the respective ports. We conducted a
web-based survey of all specialists in the sample. Each sampled
specialist was subsequently weighted in the analysis to account
statistically for all specialists in the population. Thus, the
percentages given for each question or theme can be generalized to the
entire population of CBP agriculture specialists and are estimates (at
the 95 percent confidence level). We received a response rate of 76
percent.
[3] GAO, Homeland Security: Agriculture Specialists‘ Views of Their
Work Experiences After Transfer to DHS, GAO-07-209R (Washington, D.C.:
Nov. 14, 2006).
[4] The full survey results are available in appendix II of GAO-06-644.
[5] The survey was available from November 15, 2005, until January 9,
2006.
[6] GAO, Mergers and Transformation: Lessons Learned for a Department
of Homeland Security and Other Federal Agencies, GAO-03-293SP
(Washington, D.C.: Nov. 14, 2002) and Results-Oriented Cultures:
Implementation Steps to Assist Mergers and Organizational
Transformations, GAO-03-669 (Washington, D.C.: July 2, 2003).
[End of section]
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